Australia has received considerable attention as a result of its unilateral actions to discourage multinational profit shifting. Those actions include the 2015 enactment of the Multinational Anti-Avoidance Law and the Australian Treasury's May 2016 proposal for a diverted profits tax. This...

An initiative is needed to break the logjam in the international negotiations to reform taxation of multinational enterprises (MNEs). The primary agreed goal of the project on Base Erosion and Profit Shifting (BEPS) was to better align MNEs’ taxable profits with the location of real economic...

An initiative is needed to break the logjam in the international negotiations to reform taxation of multinational enterprises (MNEs). The primary agreed goal of the project on Base Erosion and Profit Shifting (BEPS) was to better align MNEs’ taxable profits with the location of real economic...

With the OECD issuance in June 2018 of its final guidance on the profit split method, individual countries must determine how they might consider and apply the profit split method (PSM) going forward. The OECD guidance issued reflects a consensus view that included input from the very large...

Tax avoidance by multinational enterprises (MNEs) is a global problem. Most cross-border trade occurs within MNEs, susceptible to abuse of gaps and loopholes in domestic and international tax law that allow “profit shifting” between fiscal jurisdictions in order to reduce corporate tax...

By exploiting country-by-country reports (CBCRs) prepared according to the OECD BEPS Action 13's minimum standards and voluntarily published by multinational corporations (MNCs), we show that the CBCR data can be used to identify how much MNCs pay in taxes and where, as well as how important tax...

Tax avoidance by multinational enterprises (MNEs) is a global problem. Most crossborder trade occurs within MNEs, susceptible to abuse of gaps and loopholes in domestic and international tax law that allow “profit shifting” between fiscal jurisdictions in order to reduce corporate tax...

An initiative is needed to break the logjam in the international negotiations to reform taxation of multinational enterprises (MNEs). The explosion of profit shifting observed since the 1990s has resulted in hundreds of billions of dollars of tax revenues being lost around the world each year -...